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SEC Comment Letter for ANAVEX LIFE SCIENCES CORP. (AVXL) (CIK 0001314052) (AVXL) — Mar 10, 2008

ANAVEX LIFE SCIENCES CORP. (AVXL) (CIK 0001314052)
Date: March 10, 2008 · CIK: 0001314052 · Accession: 0000000000-08-012374

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File numbers found in text: 000-1314052

Date
March 5, 2008
Author
Kei Ino
Form
UPLOAD
Company
ANAVEX LIFE SCIENCES CORP. (AVXL) (CIK 0001314052)

Letter

Via Facsimile and U.S. Mail Mail Stop 6010 March 5, 2008 Mr. Harvey Lalach President, Chief Financial Officer and Secretary Anavex Life Sciences Corp. 14 Rue Kleberg, CH-1201 Geneva, Switzerland Re: Anavex Life Sciences Corp. Item 4.01 Form 8-K Filed March 4, 2008 File No. 000-1314052 Dear Mr. Lalach: We have reviewed your filing and have the following comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as detaile d as necessary in your explan ation. After reviewing this information, we may raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comment or any other aspect of our review. Feel free to call us at the telephone number listed at the end of this letter. Item 4.01

1. Please amend your Form 8-K to file as an exhibit thereto, a curre ntly dated former accountant’s letter that refe rences the Form 8-K that you are filing. Such letter must be filed within two business days of your receipt. Refer to Item 304(a)(3) of Regulation S-K.

Mr. Harvey Lalach Anavex Life Sciences Corp. March 5, 2008 Page 2 As appropriate, please amend your filing and respond to this comment within five business days or tell us when you will respond. You may wish to provide us with marked copies of the amendment to expedite our review. Please understand that we may have additional comments after reviewing your amendment and response to our comment. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filing to be certain that the filing includes all in formation required under the Securities Exchange Act of 1934 and th at they have provided all information investors require for an informed invest ment decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comment, please provide, in writing, a statement from the company acknowledging that: ‚ the company is responsible for the adequacy and accuracy of the disclosure in the filing; ‚ staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and ‚ the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filing or in response to our comments on your filing. If you have any questions, please call me at (202) 551-3659. S i n c e r e l y , K e i I n o S t a f f A c c o u n t a n t

Show Raw Text
Via Facsimile and U.S. Mail Mail Stop 6010         March 5, 2008  Mr. Harvey Lalach President, Chief Financial Officer and Secretary Anavex Life Sciences Corp. 14 Rue Kleberg,  CH-1201 Geneva, Switzerland
Re: Anavex Life Sciences Corp.
Item 4.01 Form 8-K   Filed March 4, 2008
 File No.   000-1314052
Dear Mr. Lalach:
 We have reviewed your filing and have the following comment.  Where indicated,
we think you should revise your document in response to this comment.  If you disagree,
we will consider your explanation as to why our  comment is inapplicable or a revision is
unnecessary.  Please be as detaile d as necessary in your explan ation.  After reviewing this
information, we may raise additional comments.   Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure  requirements and to  enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comment or any other aspect of our
review.  Feel free to call us at the telephone number listed at  the end of this letter.
 Item 4.01

1. Please amend your Form 8-K to file as an exhibit thereto, a curre ntly dated former
accountant’s letter that refe rences the Form 8-K that you are filing.  Such letter
must be filed within two business days of  your receipt.  Refer to Item 304(a)(3) of
Regulation S-K.

Mr. Harvey Lalach
Anavex Life Sciences Corp. March 5, 2008 Page 2    As appropriate, please amend your filing and respond to this comment within five
business days or tell us when you will respond.  You may wish to provide us with marked copies of the amendment to expedite our review.  Please understand that we may have
additional comments after reviewing your amendment and response to our comment.
  We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
  In connection with responding to our comment, please provide, in writing, a
statement from the company acknowledging that:  ‚ the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; and
‚ the company may not assert staff comments as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.     If you have any questions, please call me at (202) 551-3659.
         S i n c e r e l y ,           K e i  I n o         S t a f f  A c c o u n t a n t